Recruiting Staff for a Children's Home: Safer Recruitment, DBS, References & Schedule 2

The current position

Safer recruitment is one of the most important safeguarding functions in a children's home. The people you hire will have access to vulnerable children. Getting recruitment wrong can put children at risk. Regulation 32 and Schedule 2 of the Children's Homes (England) Regulations 2015 set out the suitability and recruitment requirements for people working in a children's home, including the information normally required before they start work and the limited exceptional-start provision in Regulation 32(7). Regulation 33 sets out the employment requirements that follow appointment, including induction and probation.

What Regulation 32 requires

Regulation 32 requires the registered person to ensure that the home is staffed by people who are fit to do their work. This means being satisfied that each relevant worker is of integrity and good character, has appropriate experience, qualifications and skills, and is physically and mentally fit for the work. Schedule 2 sets out the specific information that must be obtained before appointment. These are not optional. They are legal requirements.

Identity

Schedule 2 requires proof of identity, including a recent photograph. Current Ofsted and DBS guidance sets out acceptable identity-verification processes, which may include checking original documents or using prescribed digital identity verification routes for eligible British/Irish citizens. Previous names should be checked too, so that DBS and reference checks cover all names the person has been known by.

DBS checks

Schedule 2 requires the relevant DBS certificate. For most children's-home roles, this will be an enhanced DBS check. Whether barred-list information is included depends on whether the role is regulated activity with children and the applicable DBS eligibility rules. Current DBS guidance sets out the correct level of check for each role. The check should be done before the person starts work, not after.

A clear DBS does not mean a safe person

A DBS certificate showing no disclosed information does not prove a person is safe or suitable. DBS information is only one part of the suitability assessment. A person who has never been caught, never been reported, or who has offended outside the UK may have a certificate showing no disclosed information. The DBS is one check, not the whole assessment.

What if information appears on the DBS?

If information appears on the DBS, the home should assess it carefully. Not every conviction or caution is relevant to working with children. But some are. The home should consider the nature of the offence, how long ago it was, the person's explanation, and whether it raises concerns about their suitability. The home should not automatically reject someone for a minor offence from years ago, but should not appoint someone with a pattern of relevant offending.

DBS Update Service

If the person is on the DBS Update Service, the home can check the status of their certificate online. Current Ofsted guidance accepts use of the DBS Update Service and expects providers to be able to show how checks are managed and recorded. The home should follow current DBS guidance on when an Update Service check can be relied on and when a new check is needed.

What if someone has lived overseas?

If someone has lived overseas, a UK DBS check will not cover that period. Current official guidance may require or recommend obtaining a certificate of good conduct or equivalent from the relevant country, or taking other reasonable steps to check their background abroad. This is separate from the Schedule 2 requirement — it is additional good practice or official guidance where the person's history is not covered by UK checks. This can take time, so it should be started early in the recruitment process.

From 1 September 2026: regulated activity change

From 1 September 2026, the law changes concerning the supervision exemption in the definition of regulated activity with children. This may affect whether certain supervised roles or volunteers are in regulated activity. The change is not in force before 1 September 2026. Re-check current DBS guidance after that date to confirm the correct level of check for each role.

References

Schedule 2 requires two written references, including one from the person's most recent employer if there is one. CHH safer-recruitment practice: references should be from people who can comment on the person's work with children, not from friends or family, and should be obtained directly from the referee rather than passed through the candidate. Current Ofsted guidance says providers do not have to contact every referee to confirm authorship, although doing so is good practice, and they should investigate any doubts about the reliability of a reference.

What should a reference tell you?

A reference should tell you about the person's work, their suitability for working with children, any concerns, and why they left. CHH good practice: a very limited factual reference may provide less evidence about suitability. Where a reference leaves material questions unanswered, the provider should consider what further enquiries are needed to satisfy itself that the person is suitable.

Do references have to be verified by phone?

Current Ofsted guidance says providers do not have to telephone every referee to verify authorship, although doing so is good practice. Providers should investigate any doubts about the quality or reliability of a reference. A phone call can confirm the reference is genuine and explore areas the written reference did not cover.

What if the previous employer no longer exists?

If a previous employer no longer exists, the home should take reasonable steps to verify the employment. This might include contacting former colleagues, checking records, or using other evidence. The home should record what it did to verify the employment.

Why did previous employment end?

Schedule 2 requires verification, so far as reasonably practicable, of why previous employment or a previous position ended where it involved work with children or vulnerable adults. Current Ofsted guidance says providers should try to obtain this information from the most recent employer and other employers where relevant. Not every job the person has ever held requires this level of investigation. A reference that does not explain why the person left, or a candidate who gives inconsistent explanations, should be explored.

Full employment history and gaps

Schedule 2 requires a full employment history, together with a satisfactory written explanation of any gaps. The candidate should provide their full employment history. Any gaps must be explained in writing.

What counts as a gap?

Any period between jobs, or any period not accounted for, is a gap. This includes time spent travelling, caring for family, studying, unemployed, or doing informal work. The home should not assume a gap is suspicious, but it should understand what the person was doing during it.

Written explanation matters

The explanation for gaps should be in writing, from the candidate. This creates a record and allows the home to check whether the explanation is consistent with other information. A verbal explanation that is not recorded is harder to verify later.

Compare the application with the CV

The home should compare the application form with any CV the candidate has provided. Inconsistencies between the two should be explored. A candidate who presents different timelines on different documents may be hiding something, or may simply be careless. Either way, the home should understand why.

Qualifications

Schedule 2 requires documentary evidence of relevant qualifications. The provider should satisfy itself that the evidence is genuine and relates to the candidate. Where there is doubt, further verification with the awarding organisation may be appropriate. CHH good practice: qualification checks should connect to the home's training and development plan, not just be a recruitment tick-box.

Experience and skill matter too. A qualification shows someone has completed training. It does not show they can apply it. The interview and selection process should assess skills and experience alongside qualifications.

Physical and mental fitness

Regulation 32 requires the registered person to be satisfied that the worker is physically and mentally fit for the work. This is separate from Schedule 2. The way health information is sought is also governed by employment law, including the Equality Act 2010, which generally restricts health or disability questions before an offer is made but has specific exceptions (for example, questions about reasonable adjustments for the recruitment process, or whether the person can carry out a function intrinsic to the job).

Right to work

The home must check that the person has the right to work in the UK. This is a separate legal requirement from the Schedule 2 checks, but it should be done as part of the recruitment process. Current Home Office guidance allows different prescribed routes, including: Home Office online checks using a share code where applicable; manual original-document checks; approved digital identity verification routes for eligible British/Irish citizens; and the Employer Checking Service in specified circumstances. The home should follow the route that applies to the individual.

Interview and selection

The interview is where the home assesses whether the person is right for working with children. This is not just about experience. It is about values, attitudes and how the person talks about children.

Interviews at the home

Current Ofsted guidance says candidates interviewed at the setting must be supervised. If candidates attend the home for interview, the home should ensure they are supervised at all times.

Values-based interviewing

Values-based interviewing explores the candidate's values and attitudes, not just their experience. How do they talk about children? Do they see children as people with rights, or as problems to be managed? Do they understand safeguarding? Are they patient, reflective and willing to learn?

Scenario-based questions

Scenario-based questions test how the candidate would respond to real situations. A question like "Tell us about a time you managed a difficult situation with a child" explores their actual experience. A question like "What would you do if a child told you something worrying?" tests their safeguarding thinking.

Listen to how candidates talk about children

The way a candidate talks about children in interview is revealing. Do they use respectful language? Do they talk about children's feelings and needs? Or do they talk about children as problems, behaviours or challenges to be controlled? This is as important as any answer they give.

Should children be involved in recruitment?

Children can be involved in recruitment. CHH practical guidance: this should be done carefully. Children should not be asked to make recruitment decisions. They should be involved in a way that is meaningful to them and safe for them. Their views should be considered alongside the professional assessment, not instead of it.

Conditional offers and pre-employment

An offer should be made conditional on satisfactory completion of the remaining checks. Full Schedule 2 information is normally expected before appointment is confirmed. Regulation 32(7) provides a limited exception: a permanent worker may start before all Schedule 2 information is complete, but only where the required identity and DBS information is already satisfactory, and the remaining enquiries (Schedule 2 paragraphs 3 to 6) are being pursued. The person must be supervised when working with children, and the provider must be able to evidence the reasonable steps taken to obtain the remaining information.

Can someone start before all checks are finished?

Regulation 32(7) allows an exceptional permanent-worker start only where the required identity and DBS information (Schedule 2 paragraphs 1 and 2) is already satisfactory. The remaining Schedule 2 enquiries (paragraphs 3 to 6) may continue, but the person must be supervised when working with children. The provider must be able to evidence the reasonable steps taken to obtain the remaining information. A start before the required DBS information is available is not permitted under Regulation 32(7).

Agency staff

Current Ofsted guidance says providers using agency staff must check the identity of agency staff before they work, and must satisfy themselves that the person is suitable. The provider does not have to obtain all Schedule 2 information themselves, but may rely on evidence from the agency and must be able to demonstrate the steps taken. The home should check what the agency has verified and when.

For a previously unused agency worker required at short notice, current Ofsted guidance says as a minimum the home should: check identity; obtain written confirmation from the agency that relevant suitability checks have been completed; review evidence of suitability as soon as possible (for example, the next working day); and ensure the agency worker is not in sole charge of the home in those circumstances. The home should brief the agency worker on the children, risks, routines and expectations before they work with children.

Shadow shifts and prospective staff

Current Ofsted guidance says prospective employees may spend time in the home as part of recruitment, but they cannot be counted in staffing numbers, must be supervised at all times, and should not have access to detailed personal information about children. They are not employees until appointed.

Induction and probation

Recruitment is not finished on the first day. Regulation 33 requires each employee to complete an appropriate induction. A new staff member should be properly inducted before working unsupervised with children. Induction should cover safeguarding, the children's needs and risks, policies, routines and expectations.

Regulation 33 requires each permanent appointment to be subject to satisfactory completion of probation. Probation should be meaningful. It is a period of assessing whether the person is suitable, not just a waiting period. The home should set clear expectations, provide support, and assess the person's practice during probation. If concerns arise, they should be addressed, not ignored until probation ends.

Ongoing suitability

Suitability is ongoing. A person who was suitable when appointed may become unsuitable. The home should monitor practice, respond to concerns and take action if suitability is in question.

What if concerns arise after appointment?

If concerns arise after appointment, the home should take them seriously. This may involve investigation, supervision, training or, in serious cases, suspension and referral. The home should not ignore concerns because the person has been appointed.

DBS referrals

If a person is dismissed or removed from working with children because they harmed or posed a risk to a child, the home may have a legal duty to refer them to the DBS. Referral to the DBS barred list is a legal duty where the statutory referral criteria are met — the person has been removed from regulated activity (or would or might have been) because they harmed or posed a risk of harm to a child or vulnerable adult. The home should follow current DBS referral guidance. Referral is not automatic for every dismissal or safeguarding concern — the criteria must be met.

Safer recruitment connects to whistleblowing. Staff who raise concerns about a colleague are part of the safeguarding system. The home should have a clear whistleblowing policy and should protect staff who raise concerns in good faith.

Recruitment records

Recruitment records should show what was checked, when, by whom, and what was found. Do not just put ticks in a spreadsheet. The records should show the evidence, not just the outcome. If a concern was identified and assessed, the record should show what the concern was and how it was assessed.

CHH good practice: final recruitment sign-off should be by a person with authority, not just the person doing the checks. The sign-off should confirm that all Schedule 2 checks have been completed and are satisfactory. Current Ofsted guidance allows providers to evidence checks through staff lists or electronic records, and inspectors may ask for a sample of full recruitment records.

Using the Training Matrix and Supervision Tracker

Safer recruitment connects to training and supervision. Once someone is appointed, their training and supervision should be tracked. The Training Matrix and Supervision Tracker help the home monitor whether new staff are receiving the support they need.

Common mistakes to avoid

Key points